Hogan Lovells’ Privacy and Cybersecurity team have made a formal submission to the Information Commissioner’s Office consultation on how organisations can continue to protect people’s personal data when it is transferred outside of the UK. Our contribution is based on both our interpretation of the UK GDPR and our experience advising clients in this area, and it takes into account the legislator’s intention as well as the jurisprudence of the CJEU as applicable to UK law.
Hogan Lovells’ response follows the structure of the ICO consultation and is divided into three sections dealing with the ICO’s proposals to update its guidance, the proposed transfer risk assessment tool and the draft model international data transfer agreements.
The key points made in our response are as follows:
The submission to the ICO was authored by Eduardo Ustaran, Sian Rudgard, Katie McMullan, and Paula Garcia.
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